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Privacy Policy

Thank you for visiting the website of GeoTraveller operated by Memory Holidays Limited (“Memory”).


GeoTraveller is committed to safeguard your privacy, personal data and data of individuals (collectively "Personal Data") furnished by your use of our website so that our collection, usage, storage and transmission of the Personal Data are in accordance with the data protection principles and requirements of the Personal Data (Privacy) Ordinance under the laws of the Hong Kong Special Administrative Region and the highest consumer protection standards.

To ensure that you have full confidence on us in relation to the Personal Data, it is significant that you read and understand comprehensively the provisions in this Privacy Policy. In particular, by using our website, you are deemed to accept, agree, undertake and confirm that:


  • The disclosure of the Personal Data to us is made out of your own free will and with the necessary consent;
  • You will comply with all the terms and conditions herein;
  • The Personal Data will be stored in our database record for the use of Memory, our subsidiaries, associates, affiliates, employees, agents, service partners or other third parties who work with us and may be located outside your home country;
  • Cookies will be used on your browser which you have a choice to remove them;
  • Information will be collected for the provision of our services when you register on our website, download any materials or conduct any transactions;
  • You agree with any future amendments to our Privacy Policy;

Types of Personal Data Collected

GeoTraveller will collect, manage and monitor the Personal Data with your consent. For the purpose of providing our services to you, you are required to provide the Personal Data and non-personally identifiable information which we believe to be relevant and required to satisfy your request and to further improve our services provided to you, including without limitation:

Personal Data
o Your name; gender; age; date of birth; Education level; occupation; telephone number; home address or correspondence address; email address; etc.
Refusal to provide such information may deny you access to certain parts of our Site, or may render us unable to handle any queries or applications you are making.

Non-personally Identifiable Information
o Travel preferences such as preferred cities, date/time display preferences, flight seating and meal preferences; views; opinions; interests; favorite activities; types of browser you are currently using; types of operating systems you are currently using and the domain names of your Internet service providers etc.

Use and Purpose of Personal Data Collected

The collection of the Personal Data and non-personally identifiable information is for the use and purpose of:

  • Providing you with our services via our website;
  • Identifying you and confirming your identity when you use our website;
  • Personalizing and customizing your experience in using our website;
  • Allowing us to process and complete your travel reservations and purchases;
  • Sending you confirmations for your travel reservations and purchases;
  • Maintaining our correspondence lists;
  • Contacting you by our customer service officers when necessary;
  • Compiling statistics on the usage of our website;
  • Sending you updates, promotions and/or newsletters of information, products or services which are of interest to you (if you have signed up for them or unless you have indicated that you do not wish to receive such communication);
  • Enhancing your convenience in using our website;
  • Conducting market research surveys in order to improve our products, services and contents of our website;
  • Collecting information for our campaigns, marketing and promotion;
  • Meeting legal, governmental or regulatory requirements including without limitation disclosure or notification requirements;
  • Marketing of products and/or services by us, our agents, subsidiaries, associates, affiliates, employees, agents or other third party who work with us and may be located outside your home country;
  • Analyzing, verifying and/or checking of your credit, payment and/or status in relation to the provision of our services;
  • Processing of any payment instructions, direct debit facilities an/or credit facilities requested by you;
  • Enabling the operation of your account and/or the collection of the amounts outstanding in your account in relation to our services.


When you visit our website, we use Google Stats thru cookies to track our performance as well as checking online ads performance only. A cookie is a small amount of data that is sent to your browser and stored on your computer’s hard drive. A cookie can only be sent to your computer’s hard drive if you access our website by using your computer.

Cookies are commonly used for tracking visitors’ viewing habits and preferences in relation to the subject matters of our website. The information collected by cookies is anonymous aggregated research data, and contain no Personal Data. Cookies cannot be used to get data from your hard drive, to get your email address or to get private information from you. They can save you from registering again when re-visiting our website. Most browsers are initially set to accept cookies. If you so prefer, you can set your browser to disable cookies or inform you when they are set. However, by disabling them, you may not be able to utilize or activate certain available function in our website.

If you do not deactivate or erase the cookies, each time you use the same computer to access our website, our web servers will be notified of your visit to our website and in turn we may identify you and enable us to access your registration information, payment information, gather statistical information about usage, marketing research, track progress and participation in promotions etc.

You can determine if and how a cookie will be accepted by configuring your browser’s which is installed in the computer you are using to access our website. If you wish, you can change those configurations in your browser. If you set your preferences in the browser, you can accept all cookies, be notified when a cookie is sent or even reject all cookies. However, by disabling or rejecting all cookies by choosing the cookies-disabling or rejecting function in your browser, you may not be able to utilize or activate certain available functions in our website or you may be required to re-enter your information on our website.

Retention of Personal Data and Non-personally Identifiable Information

Your Personal Data and non-personally identifiable information provided to us will only be retained for so long as is necessary to fulfill the related purpose for which it was collected, unless their retention is required to satisfy any applicable laws or regulations.

Ownership and Disclosure of Personal Data

All the information collected on our website is owned by Memory and will not be sold or rented to any irrelevant third parties. However, the Personal Data may be disclosed to:


  • Our subsidiaries, holding companies, associates, or affiliates of, or companies controlled by, or under common control with Memory;
  • Our agents, contractors, any telecommunications operators, any third party service providers, any third party collection agencies, any credit reference agencies, any security agencies, any credit providers, banks, financial institutions, our professional advisers and any other persons under a duty of confidentiality to us;
  • Any of our actual or proposed assignees or transferees of our rights with respect to the use, disclosure, holding, processing, retention or transfer of your Personal Data.
  • In particular, your attention is specifically drawn to the following situations:
    • When you make a travel reservation on our website, we may disclose your Personal Data to third parties who work with us and may be outside your home country such as the airlines, hotels, car rental agencies or other third parties authorized by Memory.
    • Disclosure of the Personal Data may be required by law or to protect the rights and property of Memory.
    • There may be links in our website which bring you to other third party websites. You should note that the Personal Data and non-personally identifiable information which you have provided to these third party websites are not subject to our Privacy Policy and you are strongly advised to be aware of their privacy and security policies.
    • The processing of information on our website and its transmission of transaction messages relating to your travel reservations or purchases, including your Personal Data may involve transmissions over various networks (which we do not guarantee to be secure) and to various countries and further processing and storage of data in such countries.

Direct Marketing

Once you have provided us with your Personal Data, you may receive from us or from our subsidiaries, associates, affiliates, agents and contractors telephone calls, emails and direct mailings for marketing purposes. If you do not want to receive direct marketing and promotional materials from us, please write to us direct at the address set out below. We will honor your request not to use your Personal Data for future direct marketing promotions.

After 1 April 2013, for non-pre-existing personal data, in accordance with the Personal Data (Privacy) (Amendment) Ordinance 2012, we will provide you prescribed information and response channel in writing before providing your personal data to our subsidiaries, associates, affiliates, agents and contractors for direct marketing purpose and sending you any updates and/or e-newsletters. We will not do so unless we received your reply indicating that your consents or does not object to receive them. If your reply is given orally, before using your personal data in direct marketing, a confirmation in writing will be provided to you within 14 days from the date of receipt of the reply.

Security of Personal Data

We implement appropriate physical, electronic, managerial and technological measures to safeguard and secure your Personal Data. We use our best endeavors to ensure that any Personal Data collected via our website is safe and secure from interference of other third parties not related to us. The safety measures which we take include but not limited to:


  • Physical measure: Physical records containing your Personal Data will be stored in locked areas.
  • Electronic measure: Computer data containing your Personal Data will be stored on computer systems and storage media to which access is strictly controlled.
  • Managerial measure: Your Personal Data will only be accessed by our authorised personnel who are required to comply with our internal procedures in respect of the confidentiality of the Personal Data held by us.
  • Technological measure: Encryption technology, such as Secure Socket Layer encryption, may be employed for the transmission of your Personal Data.
  • Others: Our web servers are protected behind “firewalls”.

If you become aware of any security breach of our website, please do not hesitate to contact us so that we can take appropriate actions as soon as possible.

Despite the aforementioned technology and security measures, we cannot guarantee that data transmission over the Internet are 100% safe and secure and therefore we cannot give absolute assurance that your Personal Data and the information you provide to us via our website will be safe and secure at all times. We shall not be responsible for any events arising from unauthorized access to your Personal Data and shall not be held liable for any losses and damages arising from or as a result of any unauthorized access to your Personal Data.


Should a parent or guardian of a minor believe that a minor has provided us with Personal Data without their prior approval or consent, please feel free to contact our customer services department in order to ensure that such information is removed and unsubscribe them from any of our promotional contact opportunities.

Check, Access and Correction of Personal Data

You have a right to:

  • Check whether we hold any of your Personal Data;
  • Access your Personal Data held by us;
  • Require us to correct any Personal Data which is inaccurate;
  • And ascertain our policies and practices (from time to time) in relation to Personal Data and the nature of Personal Data held by us.
  • However, we may withhold your access to your Personal Data in extremely limited circumstances where it is permitted by law such as:
    • Where it might be dangerous to you if you were to access and have your Personal Data;
    • Where your Personal Data might be prejudicial to a current ongoing investigation;
    • Where your Personal Data relates to court proceedings and may be subject to discovery;
    • Where your Personal Data relates to a commercially sensitive decision-making process;
    • Other individual’s Personal Data is contained in the same record; or
    • If Memory might as a result be self-incriminated of any offence other than an offence under the Personal Data (Privacy) Ordinance.

If you request for checking, access to or correction of Personal Data or information regarding policies and practices and types of Personal Data held, you should write to us at the address set out below. Your request will be responded in writing within 40 days. A reasonable fee may be charged for the processing of any data access or correction request.

Keeping Your Password Safe and Secure

Apart from our effort on ensuring your Personal Data is safely kept and maintained, you should not disclose your Login password or account information to anyone in order to safeguard your Personal Data. Whenever you login our website, particularly on computer which does not belong to you or on public Internet terminals, please remember to logout at the end of your session. Your effort and assistance will definitely help us protect your Personal Data.

Amendments to the Privacy Policy

The Privacy Policy may be amended from time to time without prior notices to you. If there are any changes to the Private Policy, those changes will be posted on our website.

Contact Us

If you have any questions or concerns regarding our Privacy Policy, please contact us in writing and send to or mail to: Unit 2601, 26/F., Manhattan Place, 23 Wang Tai Road, Kowloon Bay, Kowloon.


I have read and agree the Privacy Policy of GeoTraveller Cruise Centers